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Environmental Effects of Transgenic Plants: The Scope and Adequacy of Regulation
resentation of interested and affected parties, of decision makers, and of specialists in risk analysis.” The way that participants are identified and involved is critical to the success of any attempt to measure, manage, or mitigate risks associated with transgenic crops. There are different disciplinary and practical perspectives that have the potential to contribute information that will improve the modeling and measurement of hazards, exposure pathways, and the relative probability of unwanted outcomes. Also, because biotechnology is controversial, participant involvement is becoming increasingly critical to the role of risk analysis in forming the basis for authority, believability, and public confidence in regulatory decision making and in the subsequent commercialization and widespread adoption of transgenic crops.
As noted in Chapter 2, risk analysis should play at least two roles in the regulation of transgenic plants. In the past, the USDA emphasized the role of decision support and has limited participation in its environmental risk assessment procedures to those who, in the judgment of decision makers, could provide information pertinent to the anticipation and measurement of environmental hazards. However, as biotechnology has become controversial, the fact that risk assessments have been done has been cited to justify U.S. agriculture’s rapid adoption of Bt and herbicide-tolerant crops. Such justifying citations involve a shift toward using risk assessment as the basis for claiming that the USDA has faithfully exercised its decision-making authority or that the public should have confidence in recombinant DNA technologies. However, USDA officials should not presume that risk analyses done purely to support internal decision making can bear the additional weight of supporting the public’s confidence in technology or government.
Communicating the idea that risks are being taken seriously is a key element. One of the surest ways to do this is to ensure that the entire process of characterizing and measuring risk is open to an array of participants representing perspectives that reflect the various sectors of the public taking an interest in agriculture and the food system. Efforts to minimize the seriousness of risks may seem warranted in virtue of the improbability of an unwanted impact or in virtue of the relative risks posed by a transgenic technology when compared to its chemically based alternative. However, when risks are denigrated by industry, regulators, or their representatives, and people who were not present when key interpretive judgments were made are told that the risks are “not serious,” the inadvertent message is that responsibilities are not being taken seriously. This situation is aggravated when citizens who express concern through intermediary organizations think they are being excluded from key processes of risk evaluation and management. The result can be a situation in which the belief of being at risk is amplified by the very